Surinam - Interest

Article 11. Interest

1. Interest arising in one of the States and paid to a resident of the other State may be taxed in that
other State.

2. However, such interest may be taxed in the State in which it arises, and according to the law of
that State, but the tax so charged shall not exceed:

(a) 5 per cent of the gross amount of the interest, if such interest is received through a bank or
equivalent financial institution;

(b) 10 per cent of the gross amount of the interest in all other cases.

3. Notwithstanding the provisions of paragraph 2, the State in which the interest arises shall not tax
interest paid to the other State or to a political subdivision or total authority thereof, or to an agency
or body (including a financial institution) which is wholly owned by that State or by such a political
subdivision or local authority.

4. The term “interest” as used in this article means income from government securities, bonds or
debentures, whether or not secured by mortgage but not carrying a right to participate in profits, and
debt-claims of every kind not secured by mortgage, as well as all other income assimilated by virtue
of the taxation law of the State in which the income arises to income from money lent.

5. The provisions of paragraphs 1, 2 and 3 shall not apply if the recipient of the interest, being a
resident of one of the States, has in the other State in which the interest arises a permanent
establishment with which the debt-claim from which the interest arises is effectively connected. In
such a case the provisions of article 7 shall apply.

6. Interest shall be deemed to arise in one of the States when the payer is that State itself, a political
subdivision, a local authority or a resident of that State. Where, however, the person paying the
interest, whether he is a resident of one of the States or not, has in one of the States a permanent
establishment in connexion with which the indebtedness on which the interest is paid was incurred,
and such interest is borne by such a permanent establishment, then such interest shall be deemed to
arise in the State in which the permanent establishment is situated.

7. Where, owing to a special relationship between the payer and the recipient or between both of
them and some other person, the amount of the interest paid, having regard to the debt-claim for
which it is paid, exceeds the amount which would have been agreed upon by the payer and the
recipient in the absence of such relationship, the provisions of this article shall apply only to the lastmentioned
amount. In that case, the excess part of the payment shall remain taxable according to the
law of each State, due regard being had to the other provisions of this Convention.

Protocol:

VII. Ad articles 10, 11 and 12.

Applications for the refund of taxes collected contrary to the provisions of
articles 10, 11 and 12 must be submitted to the competent authority of the State which collected the
tax within a period of five years after the end of the calendar year in which the tax was collected.